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Technical Committee on Ovens and Furnaces

Date: August 29, 2013 To: Technical Committee on Ovens and Furnaces From: Derek Duval, Staff Liaison/Fire Protection Engineer Re: Agenda Package – NFPA 86 A2014 Second Draft Meeting – October 2-3, 2013 Enclosed is the agenda package for the October 2-3, 2013 meeting for the NFPA 86 Second Draft Meeting. Please ensure that you have reviewed the public input and the other agenda items in advance to prepare for discussion. The agenda and public comment will be posted on the document information page (www.nfpa.org/86). Some items to have available during the meeting include:

Agenda package with public input A copy of NFPA 86 (visit the NFPA 86 Document information page for your free committee

copy) First Draft of NFPA 86 (Under ‘Next Edition’ tab on the document information page, Heading

First Draft) First Revision Report (Under ‘Next Edition’ tab, Heading First Draft Ballot) A laptop

Optional items that are sometimes useful include: Review of NFPA’a New Process, www.nfpa.org/newregs Review of NFPA Regulations Previous copies of NFPA 86

If you have any questions or comments, please feel free to contact Joanne Goyette at (617) 984-7950 or by email at [email protected].

Technical Committee on Ovens and Furnaces AGENDA

October 2-3, 2012 Liberty Mutual, Weston MA

8:00 a.m. to 6:00 p.m. (Eastern Time Zone) 1. Meeting opening, introduction and attendance

2. Chair's remarks, Rich Gallagher

3. Approval of Minutes from the October 2012 First Draft Meeting (Attachment A, OVE-AAA

Minutes NFPA 86 First Draft Oct 2012)

4. Staff Liaison update:

a. A2014 Schedule (Attachment B, A2014 Revision Cycle)

b. Committee Membership Update (Attachment C, OVE-AAA Membership)

c. New Standards Process Review (Attachment D, New Process – Quick Reference Guide)

5. New Business

a. Public Comments (Attachment E, NFPA 86 - A2014 Public Comments)

b. Development of Second Revisions (Attachment D, New Process – Quick Reference

Guide)

6. Other business

7. Date/Location of Next Meeting. (T.B.D.)

8. Adjournment

Attachments:

A. OVE-AAA Minutes NFPA 86 First Draft Oct 2012

B. A2014 – Revision Cycle

C. OVE-AAA Committee Membership

D. New Process – Quick Reference Guide

E. NFPA 86 - A2014 Public Comments

Attachment A: OVE-AAA Minutes NFPA 86 First

Draft

Minutes “First Draft Meeting”

NFPA 86 Technical Committee on Ovens & Furnaces Zurich North America Headquarters – Schaumburg, Illinois

23-24 October 2012

1. Attendees: Derek Duvall, Rich Gallagher, Rick Martin, John Dauer, Trey Morrison, Jak Kozma,

Tom George, Ted Jablkowski, Al Underys, Doug Perry, Dan Curry, Gary Keil, Fausta Lyons, Elliott

Davis, Clemens DeVroome, Mark Stender, Keith Hancock, Frank Kaczmarczyk, Scott Musser, Ed

Baldwin, Scott Johnston, Bob Daley, Glen Mortensen, Kevin Carlisle, Bill Sheppard, Bill Rucki,

Gary Andress, John Higginbotham, Amy Brown, Mike Polagye.

2. Phone Attendees: Ray Serafini, Kevin Ray, Reepa Shroff (guest)

3. Chair Introduction:

a. On Tuesday morning, Rich Gallagher called the meeting to order.

b. The group held a moment of silence for two members passed on since last meeting –

John Barron and Jacques VanHenningen.

c. Mergers – CEC Combustion + Eclipse

d. New Principal Members: Doug Perry, Frank Kaczmarczyk, Scott Musser, Jason

Sroczynski

e. New Alternates: Bruce Mickelson, Keith Hancock, Bill Rucki

f. Retirements: Dave Herron, Randy Bal

g. Half the committee members do not have alternates. Consider getting an alternate!

h. New Staff Liason – Welcome Derek Duvall, who replaced Ted Lemoff

i. Old Buzzard Awards: Ray Ostrowski 46 years; Bill Sheppard 32 years; Al Underys 24

years; Pete Willse 24 years.

4. Staff Liaison Introduction:

a. Discussed working guidelines for NFPA technical committees.

b. Current makeup of TC: 6 Insurance, 1 Installer/Maintainer, 9 Manufacturer, 6 Special

Expert, 5 User

c. See Calendar posted on website (www.nfpa.org/86) for NFPA imposed deadlines.

d. 2nd Draft Meeting to be held sometime before October 18, 2013.

e. Next Edition will be 2015 Editions, with effective date of May or August 2014.

f. New terminology (First Draft Meeting, Public Input, Committee Input, etc.) – see terms

posted on website.

5. Work Conducted on First Day (Tuesday):

a. The Technical Committee resolved approximately 95 public and committee input items,

and generated approximately 74 First Revisions.

6. Work Conducted on Second Day (Wednesday):

a. The Technical Committee resolved approximately 62 public and committee input items,

and generated approximately 41 First Revisions.

b. The Technical Committee considered but did not act on a suggestion that Chapter 8

might be clearer if split into two separate chapters:

http://www.nfpa.org/86

i. A first part containing requirements for the features, performance and reliability

of safety devices (including logic systems).

ii. A second part containing requirements for how, when, and where safety

devices (including logic systems) are to be applied.

7. Tentative Date for 2nd Draft Meeting:

a. Tuesday, and possibly Wednesday of the week of September 16

b. Possibly in Weston, MA at Liberty Mutual Property Headquarters

8. Discussion about Traditional Ovens & Furnaces Safety Training

a. Does NFPA want to hold a training seminar on a regular basis that provides insight on

NFPA 86 to the public?

b. NFPA 86 TC will explore whether this is an opportunity that makes sense.

c. Maybe the audience could be broader than past seminars – include Enforcer and

Insurance categories.

d. Maybe a format similar to Combustible Dust Safety seminar conducted recently by

NFPA.

e. A Task Group was designated to research this possibility further.

9. Chair Closing Statement

a. The Technical Committee expresses its sincere appreciation and gratitude to Zurich

North America, and especially to Glen Mortenson and Rich Gallagher for their

outstanding hospitality over the course of this meeting.

b. On Wednesday evening, Rich Gallagher thanked the Technical Committee for their hard

work and adjourned the meeting.

Respectfully submitted,

Rick Martin Secretary, NFPA 86 Technical Committee

Attachment B: A2014 Revision Cycle

NFPA 86 Revision Cycle – KEY DATES Annual 2014

NFPA A2014 [OVE-AAA]

Important Dates For the Cycle:

Public Comment Closing May 3, 2013 (DONE)

Second Draft Meeting October 2-3, 2013

Posting of Section Draft January 3, 2014

Notice of Intent to Make Motion (NITMAM) February 7, 2014

Issuance of Consent Standard May 9, 2014 (published bit later)

NFPA Annual Meeting with CAMs June 9-12, 2014

Issuance of Standard – with CAMs August 14, 2014 (published bit later)

Process Stage Process Step Dates for TC Dates for TCC

Public Input Closing Date ‐ Electronic 6/22/2012 6/22/2012Final date for TC First Draft Meeting 11/30/2012 8/31/2012Posting of First Draft and TC Ballot 1/18/2013 10/12/2012Final date for Receipt of TC First Draft ballot 2/8/2013 11/2/2012Final date for Receipt of TC First Draft ballot ‐ recirc 2/15/2013 11/9/2012Posting of First Draft for CC Meeting 11/16/2012Final date for CC First Draft Meeting 12/28/2012Posting of First Draft and CC Ballot 1/18/2013Final date for Receipt of CC First Draft ballot 2/8/2013Final date for Receipt of CC First Draft ballot ‐ recirc 2/15/2013Post Final First Draft for Public Comment 2/22/2013 2/22/2013

Public Comment closing date ‐ Electronic 5/3/2013 5/3/2013Final Date to Publish Notice of Consent Documents 5/10/2013 5/10/2013Appeal Closing Date for Consent Documents 5/24/2013 5/24/2013Final date for TC Second Draft Meeting 10/18/2013 7/12/2013Posting of Second Draft and TC Ballot 11/29/2013 8/23/2013Final date for Receipt of TC Second Draft Ballot 12/20/2013 9/13/2013Final date for receipt of TC Second Draft ballot ‐ recirc 12/27/2013 9/20/2013Posting of Second Draft for CC Mtg 9/27/2013Final date for CC Second Draft Meeting 11/8/2013Posting of Second Draft and CC Ballot 11/29/2013Final date for Receipt of CC Second Draft ballot 12/20/2013Final date for Receipt of CC Second Draft ballot ‐ recirc 12/27/2013Post Final Second Draft for NITMAM Review 1/3/2014 1/3/2014

Notice of Intent to Make a Motion (NITMAM) Closing Date 2/7/2014 2/7/2014Posting of Certified Amending Motions and Consent Documents 4/4/2014 4/4/2014Appeal Closing Date for Consent Documents 4/18/2014 4/18/2014SC Issuance Date for Consent Documents 5/9/2014 5/9/2014

Tech Session Association Meeting for Documents with CAMs 6/9‐12/2014 6/9‐12/2014

Appeal Closing Date for Documents with CAMs 6/24/2014 6/24/2014SC Issuance Dates for Documents with CAMs 8/12‐14/2014 8/12‐14/2014

Annual 2014 Revision Cycle (New Process)

Comment Stage

(Second Draft)

Tech Session

Preparation

(& Issuance)

Appeals and

Issuance

Public Input

Stage

(First Draft)

Attachment C: OVE-AAA Committee Membership

Address List No PhoneOvens and Furnaces OVE-AAA

Derek Duval08/22/2013

OVE-AAA

Richard A. Gallagher

ChairZurich Services Corporation5124 New Kent RoadWilmington, DE 19808Alternate: Glen R. Mortensen

I 1/1/1990OVE-AAA

Richard J. Martin

SecretaryMartin Thermal EngineeringPO Box 873Manhattan Beach, CA 90267

SE 7/20/2000

OVE-AAA

Gary S. Andress

PrincipalLiberty Mutual PropertyEngineering Services20 Riverside RoadWeston, MA 02493-2231Alternate: Brent D. Hill

I 1/1/1992OVE-AAA

Kevin J. Carlisle

PrincipalKarl Dungs, Inc.3890 Pheasant Ridge Drive, NEBlaine, MN 55449Industrial Heating Equipment AssociationAlternate: Elliott Davis

M 4/14/2005

OVE-AAA

Erik W. Christiansen

PrincipalExponent, Inc.5401 McConnell AvenueLos Angeles, CA 90066-7027Alternate: Delmar R. “Trey” Morrison III

SE 9/30/2004OVE-AAA

Randall Conklen

PrincipalCaterpillar Incorporated901 West Washington St., Bldg. MM2East Peoria, IL 61630-7650Alternate: Scott Johnston

U 4/28/2000

OVE-AAA

Dan Curry

PrincipalEclipse, Inc.1665 Elmwood RoadRockford, IL 61103Alternate: Bryan R. Baesel

M 1/14/2005OVE-AAA

Robert Daley

PrincipalSolar Atmospheres Manufacturing, Inc.1983 Clearview RoadSouderton, PA 18964Alternate: Robert J. Wilson

M 10/4/2007

OVE-AAA

John Dauer

PrincipalSCC, Inc.1250 Lunt AvenueElk Grove, IL 60007Alternate: Peter S. Pinto

M 1/16/2003OVE-AAA

Thomas B. George

PrincipalTokio Marine Management, Inc.800 East Colorado BoulevardPasadena, CA 91101

I 4/14/2005

OVE-AAA

John E. Higginbotham

PrincipalAlcoa, Inc.GRP Engineering, Tennessee Operations300 North Hall Road - S029Alcoa, TN 37701

U 4/3/2003OVE-AAA

E. Richard Huggins

PrincipalTechnical Standards & Safety Authority (TSSA)3300 Bloor Street WestCentre Tower, 14th FloorToronto, ON M8X 2X4 Canada

E 07/29/2013

OVE-AAA

Ted Jablkowski

PrincipalFives North American Combustion, Inc.287 Boston Post RoadPO Box 160East Lyme, CT 06333Alternate: William M. Rucki

M 7/22/1999OVE-AAA

Kai-Eric Jensen

PrincipalJensen Industries, Inc.2111 Thompson RoadFenton, MI 48430

M 7/17/1998

1



OVE-AAA

Frank J. Kaczmarczyk

PrincipalCarpenter Technology Corporation101 West Bern StreetReading, PA 19601-1203

U 03/05/2012OVE-AAA

Joseph A. (Jak) Kozma III

PrincipalAFC-Holcroft LLC49630 Pontiac TrailWixom, MI 48393-2009Alternate: William M. Keough

M 8/5/2009

OVE-AAA

Joel Liggins

PrincipalToyota Motor Engineering & Manufacturing NA301 James Lawrence RoadJackson, TN 38301

U 07/29/2013OVE-AAA

Scott D. Musser

PrincipalRPA Engineering101 West Bern StreetReading, PA 19601-1203

SE 03/05/2012

OVE-AAA

Raymond Ostrowski

PrincipalConsultant-Industrial Safety30642 North 41st WayCave Creek, AZ 85331Alternate: J. William Sheppard

SE 10/6/2000OVE-AAA

Douglas M. Perry

PrincipalMaxon/Honeywell Company201 East 18th StreetMuncie, IN 47302Alternate: Bruce L. Mickelson

M 08/09/2012

OVE-AAA

Michael C. Polagye

PrincipalFM GlobalEngineering Standards1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Alternate: Amy Brown

I 1/1/1990OVE-AAA

Geoffrey A. Raifsnider

PrincipalGlobal Finishing Solutions12731 Norway RoadOsseo, WI 54758

M 07/29/2013

OVE-AAA

Raymond E. Serafini, Jr.

PrincipalLinde, LLCRR #2, Box 535Brockway, PA 15824

IM 4/5/2001OVE-AAA

Jason Sroczynski

PrincipalJayco Enterprises Inc.27800 Lemoyne Road, Suite HMillbury, OH 43447

SE 03/05/2012

OVE-AAA

Mark V. Stender

PrincipalSurface Combustion, Inc.1700 Indian Wood CirclePO Box 428Maumee, OH 43537-0428Alternate: Keith A. Hancock

M 1/15/1999OVE-AAA

Franklin R. Switzer, Jr.

PrincipalS-afe, Inc.2405 West Sacramento DriveMuncie, IN 47303-9002Alternate: Clemens J. Schultz

SE 4/17/2002

OVE-AAA

Grant F. Tiefenbruck

Principal3M Company3M Center, Building 518-1-01St. Paul, MN 55144Alternate: James J. Garmaker

U 1/1/1990OVE-AAA

Jay D. Tindall

PrincipalParagon Risk Engineering105 Seneca Farm DriveHarmony, PA 16037Alternate: Lee M. Rebodos

I 4/1/1996

2



OVE-AAA

Algirdas Underys

PrincipalA. Finkl & Sons Co.2011 Southport AvenueChicago, IL 60614Forging Industry Association

U 10/19/1988OVE-AAA

Peter J. Willse

PrincipalXL Global Asset Protection Services100 Constitution Plaza, 12th FloorHartford, CT 06103

I 1/1/1988

OVE-AAA

Bryan R. Baesel

AlternateEclipse/CEC Combustion Safety, Inc.11699 Brookpark RoadCleveland, OH 44130Principal: Dan Curry

M 1/16/2003OVE-AAA

Amy Brown

AlternateFM Global1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Principal: Michael C. Polagye

I 03/07/2013

OVE-AAA

Elliott Davis

AlternateSelas Heat Technology130 Keystone DriveMontgomeryville, PA 18936Industrial Heating Equipment AssociationPrincipal: Kevin J. Carlisle

M 07/29/2013OVE-AAA

James J. Garmaker

Alternate3M Company3M Center, Building 275-6W-22St. Paul, MN 55144-1000Principal: Grant F. Tiefenbruck

U 1/10/2002

OVE-AAA

Keith A. Hancock

AlternateSurface Combustion, Inc.1700 Indian Wood CirclePO Box 428Maumee, OH 43537-0428Principal: Mark V. Stender

M 8/9/2011OVE-AAA

Brent D. Hill

AlternateLiberty Mutual Property8505 Pebblebrook DriveFrisco, TX 75034Principal: Gary S. Andress

I 10/4/2001

OVE-AAA

Scott Johnston

AlternateCaterpillar IncorporatedOld Galena RoadTechnical Center-K/854Mossville, IL 61552Principal: Randall Conklen

U 03/07/2013OVE-AAA

William M. Keough

AlternateAFC-Holcroft LLC49630 Pontiac TrailWixom, MI 48393-2009Principal: Joseph A. (Jak) Kozma III

M 1/10/2002

OVE-AAA

Bruce L. Mickelson

AlternateHoneywell International, Inc.1985 Douglas Drive NorthMail Station: MN10-2497Golden Valley, MN 55422Principal: Douglas M. Perry

M 8/9/2011OVE-AAA

Delmar R. “Trey” Morrison III

AlternateExponent, Inc.1011 Warrenville Road, Suite 215Lisle, IL 60532-0906Principal: Erik W. Christiansen

SE 8/2/2010

3



OVE-AAA

Glen R. Mortensen

AlternateZurich Services CorporationRisk Engineering21337 West Crescent DriveMundelein, IL 60060-3399Principal: Richard A. Gallagher

I 1/1/1990OVE-AAA

Peter S. Pinto

AlternateSCC, Inc.1250 Lunt AvenueElk Grove Village, IL 60007Principal: John Dauer

M 8/5/2009

OVE-AAA

Lee M. Rebodos

AlternateParagon Risk Engineering1417 Doubletree TrailFlower Mound, TX 75028Principal: Jay D. Tindall

I 4/3/2003OVE-AAA

William M. Rucki

AlternateFives North American Combustion, Inc.4455 East 71st StreetCleveland, OH 44105Principal: Ted Jablkowski

M 08/09/2012

OVE-AAA

Clemens J. Schultz

AlternateCSS Contract Services LLCPO Box 3184598 Weston Falls AvenueNeillsville, WI 54456Principal: Franklin R. Switzer, Jr.

SE 8/5/2009OVE-AAA

J. William Sheppard

AlternateSheppard & Associates, LLC24756 Tudor LaneFranklin, MI 48025Principal: Raymond Ostrowski

SE 1/1/1980

OVE-AAA

Robert J. Wilson

AlternateSolar Manufacturing Inc.1983 Clearview RoadSouderton, PA 18964Principal: Robert Daley

M 03/07/2013OVE-AAA

Derek Duval

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

4/29/2011

4

Attachment D: New Process – Quick Reference Guide

New Process (Second Draft Stage) – Quick Reference Guide For additional information on the New Regulations visit: www.nfpa.org/NewRegs A Technical Committee (TC) can take these actions at the Second Draft (ROC) meeting:

1. Resolve a Public Comment • Accept • Reject, But See Related Second Revision • Reject • Reject But hold

2. Create a Second Revision NOTE: All actions require a Committee Statement.

Resolve Public Comment (TC needs to act upon all the Public Comments)

• Accept • The TC takes the text exactly as submitted by the public comment and creates a

second revision. • Sample Motion: “I move to accept PC#_.” • Approval by meeting vote (simple majority) and final approval through ballot.

• Reject but See • The TC agrees with the concept of the PC in whole or part but wants to edit the

text to create a second revision. • Sample Motions:

i. “I move to reject PC#__, but create a second revision using it as a basis.” ii. “I move to make a second revision using PC#__ as a basis.”

• Approval by meeting vote (simple majority) and final approval through ballot. • Reject

• The TC disagrees with the proposed changes in the public comment. • Sample Motion: “I move to reject PC#__.” • Approval by meeting vote (simple majority). Not subject to ballot.

• Reject, but Hold. • The TC may hold any comment until the public input stage of the next revision

cycle meeting any of the following criteria: i. New concept that has not had any public review

ii. The changed text would require the technical committee to restudy the change

iii. The proposed concept cannot be handled in the second draft timeframe • Sample Motion: “I move to hold PC#__.” • Approval by meeting vote (simple majority). Not subject to ballot.

Create a Second Revision (change to the document)

• TC must create a Second Revision (SR) for each change they wish to make to the document. The TC can either choose to use a Public Comment for the basis of the change or not.

http://www.nfpa.org/NewRegs�

• Using Public Comment for basis: i. See above for ACCEPT or REJECT BUT SEE.

• Without using Public Comment for basis i. Sample Motion: “I make a motion to revise section __ as follows___.”

Approval by meeting vote (simple majority) and final approval through ballot.

Comparison to Previous Process:

PREVIOUS ACTIONS NEW PROCESS ACTIONS Sample Motion

Accept

1) Committee generates a Second Revision and Substantiation (CS) for change 2) Committee provides response (CS) to each PC.

1) “I move to accept PC#__.”

Any variation of Accept (APA, APR, APP) on a public comment

1) Committee rejects the comment, but creates a Second Revision 2) Committee provides response (CS) to each PC that is associated with the revision

1) “I move to revise section __ using PC#_ as the basis for change.” 2) “I move to reject PC#__, but create a second revision using it as a basis.”

Rejected Public Comment

1) Committee rejects the comment 2) Committee provides response (CS) to PC

“I make a motion to reject PC#_ with the following committee statement__.”

Accepted Committee Comment Committee generates a Second Revision and Substantiation (CS) for change

“I make a motion to revise section __ as follows___.” Committee generates a statement for reason for change.

Notes: 1) All meeting actions require a favorable vote of a simple majority of the members present. 2) All Second Revisions will be contained in the ballot and will require a 2/3 affirmative vote

to confirm the meeting action. 3) Only the Second Revisions will be balloted. PCs will be contained in the report but will not

be balloted.

New Terms:

NEW TERM OLD TERM

Input Stage ROP Stage

Public Input (PI) Proposal

First Draft Meeting ROP Meeting

Committee Input Committee Proposal that Fail Ballot

Committee Statement (CS) Committee Statement

First Revision (FR) Committee Proposal or Accepted Public Proposal

First Draft Report ROP

First Draft ROP Draft

Comment Stage ROC Stage

Public Comment Public Comment

Second Draft Meeting ROC Meeting

Committee Comment Committee Comment that Fail Ballot

Committee Action Committee Action

Second Revision Committee Comment or Accepted Public Comment

Second Draft Report ROC

Second Draft ROC Draft

Note: The highlighted terms are the ones that will be most applicable at the Second Draft Meeting.

Attachment E: NFPA 86 – A2014 Public Comments

8/7/13 TerraView™

submittals.nfpa.org/TerraViewWeb/ViewerPage.jsp 1/45

Public Comment No. 18-NFPA 86-2013 [ Section No. 3.3.6 ]

3.3.6* Burner Management System.

The field devices, logic system, and final control elements dedicated to combustion safety and operator assistance in thestarting and stopping of fuel preparation and burning equipment and for preventing misoperation of and damage to fuelpreparation and burning equipment. [85:2011]

Statement of Problem and Substantiation for Public Comment

This definition matches the definition of Burner Management System in NFPA 85. An extract notation should be added.

Submitter Information Verification

Submitter Full Name:Susan Desrocher

Organization: [ Not Specified ]

Affilliation: Glossary of Terms Committee member

Street Address:

City:

State:

Zip:

Submittal Date: Fri Apr 26 16:40:22 EDT 2013

Copyright Assignment

I, Susan Desrocher, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment

(including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a

joint author, in any publication of the NFPA in w hich this Public Comment in this or another similar or derivative form is used. I hereby w arrant that I am the

author of this Public Comment and that I have full pow er and authority to enter into this copyright assignment.

By checking this box I aff irm that I am Susan Desrocher, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions

contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that w ill, upon my submission of this form, have the

same legal force and effect as a handw ritten signature

8/7/13 TerraView™



3.3.11 Combustion Safeguard.

A safety device directly responsive to flame properties that senses the presence or absence of flame using flame sensors andde-energizes the fuel safety shutoff valve in the event of flame failure . [87, 2011]


The common use of combustion safeguard has always been understood as more than just a detector of flame (i.e., only flame sensor and amplifier). For example, the FM 6-0 data sheet describes it as a safety 'control'. The term safeguard and control both imply an action, not just sensing. A 'flame detector' is a more appropriate term for sensing. See PC No. 24.


Submitter Full Name:Dan Curry

Organization: Eclipse, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Mon Apr 29 17:53:47 EDT 2013


I, Dan Curry, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment




By checking this box I aff irm that I am Dan Curry, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions



8/7/13 TerraView™


Public Comment No. 24-NFPA 86-2013 [ New Section after 3.3.17 ]

Flame detector.

A safety device directly responsive to flame properties that senses the presence or absence of flame using flame sensors.


The new term 'flame detector' is better than 'combustion safeguard' with this definition. This term and definition aligns with CSA C22.2 NO. 199 / ANSI Z21.20 / UL 372 standards as used in the industry. This new term should replace 'combustion safeguard' where used through-out the introductory chapters. See PC No. 23.




Street Address:

City:

State:

Zip:










8/7/13 TerraView™



3.3.18 Flame Failure Detector Response Time (FFRT FDRT ).

The period of time that starts with the loss of flame and ends with the loss of flame signal from the combustion safeguard.


The definition term is changed to avoid confusion in the industry. The standards CSA C22.2 NO. 199 / ANSI Z21.20 / UL 372 (dealing with safety controls for burner ignition) uses 'FLAME DETECTOR RESPONSE TIME: The period of time between the loss of the sensed flame and the signal indicating the absence of flame.'




Street Address:

City:

State:

Zip:










8/7/13 TerraView™



3.3.20 Flame Response Time (FRT).

The period of time that starts with the loss of flame and ends with the de-energizing of the safet shutoff valve(s).

See the uploaded file which includes an equation and a table.

Additional Proposed Changes

File Name Description Approved

First_Revision_No._105_leak_testing_procedure_for_SSOV_rev_1.pdf Cover Sheet includes equations & tables


Replace equation with the one in this proposal, and add the following that is underlined.


Submitter Full Name:Kevin Carlisle

Organization: Karl Dungs, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Apr 25 10:24:57 EDT 2013


I, Kevin Carlisle, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment




By checking this box I aff irm that I am Kevin Carlisle, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions



NFPA Public Comment Form (For Proposing Revisions to the First Draft)

NOTE: All Public Comments must be received by 5:00 pm EST/EDST on the published Public Comment Closing Date.

For further information on the standards-making process, please contact the Codes and Standards Administration at 617-984-7249 or visit www.nfpa.org/codes.

For technical assistance, please call NFPA at 1-800-344-3555

FOR OFFICE USE ONLY

Log #:

Date Rec’d:

Date 4-22-2013 Name Kevin Carlisle Tel. No. 763-582-1743

Company Karl Dungs, Inc Email [email protected]

Street Address City Blaine State MN Zip 55449

Please indicate organization represented (if any)

1. (a) NFPA Document Title

Ovens and Dryers NFPA No. & Year 86-2011

(b) Section/Paragraph First Revision No. 105 para 3.3.20

2. Identify First Revision and/or Input to which Comment relates: No(s).

2. Public Comment Recommends (check one): new text revised text deleted text

3. Proposed Text of Public Comment (include proposed new or revised wording, or identification of wording to be deleted): [Note: Proposed text should be in legislative format showing proposed changes to the First Draft; i.e., use underscore to denote wording to be inserted (inserted wording) and strike-through to denote wording to be deleted (deleted wording).]

L= leakage rate (cm3/hr) IΔpI = absolute value of initial test pressure (mbar) - final test pressure (mbar). Vtest = total volume of the test (in cm3) Patm = atmospheric pressure (atmospheres) Ttest = test time (in seconds) Conversation factors

1”WC = 2.44mbar. 1 PSI = 27.7 “WC 1 atmosphere = 14.7 PSI.

This test method can be done by tapping into the following ports and performing the following test method

Test port location Test method

A test port in between both safety shutoff valves

Pressure decay on V2 Pressure rise on V1

A test port test port downstream both safety shutoff valves

Pressure rise on V1 and V2 (requires manual shutoff valve downstream both safety shutoff valves and that is be leak tightness tested).

A test port that is upstream both valves

Pressure decay on V1 and V2(requires a leak tightness test on the upstream, manual isolation valve)

http://www.nfpa.org/codes

4. Statement of Problem and Substantiation for Public Comment: (Note: State the problem that would be resolved by your recommendation; give the specific reason for your Public Comment, including copies of tests, research papers, fire experience, etc. If more than 200 words, it may be abstracted for publication.)

Replace equation with the one in this proposal, and add the following that is underlined.

5. Copyright Assignment

(a) I am the author of the text or other material (such as illustrations, graphs) proposed in the Public Comment.

(b) Some or all of the text or other material proposed in this Public Comment was not authored by me. Its source is as follows: (please identify which material and provide complete information on its source)

I hereby grant and assign to the NFPA all and full rights in copyright in this Public Comment (including both the Proposed Text and the Statement of Problem and Substantiation). I understand that I acquire no rights in any publication of NFPA in which this Public Comment in this or another similar or analogous form is used. Except to the extent that I do not have authority to make an assignment in materials that I have identified in (b) above, I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this assignment.

Signature (Required)

PLEASE USE SEPARATE FORM FOR EACH PUBLIC COMMENT To: Secretary, Standards Council National Fire Protection Association

1 Batterymarch Park ∙ Quincy, MA 02169-7471 OR Fax to: (617) 770-3500 OR Email to: [email protected]

4/23/2013

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3.3.20 Flame Response Time (FRT).

The period of time that starts with the actual loss of flame and ends with the power loss ( de-energizing of the safetenergization) to the safety shutoff valve(s).



First_Revision_No._143_FFRT.pdf Cover Sheet


The revision clarified that FRT starts at the “beginning of actual loss of flame (not the detected loss of flame) and ends when the command of logic releases the SSOV to close and de-energize; it does not include SSOV closing time.




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3.3.20 Flame Response Time (FRT). The period of time that starts with the actual loss of flame and ends with the power loss (de-energization) to the de-energizing of the safety shutoff valve(s).


The revision clarified that FRT starts at the “beginning of actual loss of flame (not the detected loss of flame) and ends when the command of logic releases the SSOV to close and de-energize; it does not include SSOV closing time.







1 Batterymarch Park ∙ Quincy, MA 02169-7471 OR


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3.3.20 Flame Failure Response Time (FRT FFRT ).

The period of time that starts with the loss of flame and ends with the de-energizing of the safet shutoff valve(s).


To avoid confusion in the industry, follow the safety standards for burner ignition controls, CSA C22.2 NO. 199 / ANSI Z21.20 / UL 372, which uses 'FLAME FAILURE RESPONSE TIME: The period of time between loss of supervised ignition source or the supervised main burner flame and the action to shut off the fuel supply.




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Public Comment No. 19-NFPA 86-2013 [ Section No. 3.3.55.1 ]

3.3.55.1 Line Pressure Regulator.

A pressure regulator placed in a gas line between the service regulator and the appliance (equipment) regulator. regulator.[54:2012]


As a member of the GOT Committee, I would like to see this definition modified to match the existing definition used in NFPA 54. The GOT Committee's work has been to create general and consistent definitions of the same term. The word "(equipment)" makes this a new, unique definition.





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3.3.55.4 Service Pressure Regulator Regulator .

A pressure regulator installed by the serving gas supplier to reduce and limit the service line gas pressure to delivery pressure.[54:2012]


As a representative of the GOT Committee, I can report that the GOT committee would like to see modification of this definition. The GOT Committee's work has been to create general and consistent definitions of the same term throughout the NFPA system of documents. The text of this definition is exactly the same as the definition of "Service Regulator" used in NFPA 54. The use of the word, "Pressure" in the term itself creates a new, unique definition, and that would be going in the wrong direction for the Glossary of Terms, as recommended by the NFPA Standards Council.




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3.3.56 Pressure Relief Valve.

A valve that automatically opens and closes a relief vent, depending on whether the pressure is above or below a predeterminedvalue.[54:2012]


This definition is the same as that used in NFPA 54. An extract notation should be added.





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3.3.57 Ventilation.

A supply

The changing of

fresh air to, and exhaust from, a furnace that provides a vigorous, distributed flow of air through all sections of the furnace.

air within a compartment by natural or mechanical means. [69:2008]

3.3.57.1 * Safety Ventilation.

The ventilation necessary to dilute atmosphere within a Class A oven to not exceed the maximum permitted percent of theLower Flammable Limit (LFL).


As a member of the GOT Committee, I am against the addition of this definition in its present language. The GOT Committee's work has been to create general and consistent definitions of the same term. Before this addition of this definition at the ROP, there were 10 definitions of "Ventilation" in the Glossary of Terms. The GOT Committee suggests adding a more generic definition already in the Glossary, such as the one used in 1925 and 69, which is also the first sentence of 402. Adding this definition as written in the ROP creates another unique definition of "Ventilation." This is going in the wrong direction for the Glossary of Terms.




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6.2.6.8

Vent lines from multiple regulators and switches of a single furnace, where manifolded together, shall be piped in such amanner that diaphragm rupture

of

feeding gas to one vent line does not backload the others.

6.2.6.8.1

Vents from systems operating at different pressure levels shall not be manifolded together.

6.2.6.8.2

Vents from systems served from different pressure-reducing stations shall not be manifolded together.

6.2.6.8.3

Vents from systems using different fuel sources shall not be manifolded together.



First_Revision_No._2_vent_lines.pdf Cover Sheet


Clarifies the requirement since vent lines do not rupture, diaphragms can.




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(b) Section/Paragraph First Revision No. 2 para 6.2.6.8




6.2.6.8 Vent lines from multiple regulators and switches of a single furnace, where manifolded together, shall be piped in such a manner that a diaphragm rupture feeding gas to of one vent line does not backload the others. 6.2.6.8.1 Vents from systems operating at different pressure levels shall not be manifolded together. 6.2.6.8.2 Vents from systems served from different pressure-reducing stations shall not be manifolded together. 6.2.6.8.3 Vents from systems using different fuel sources shall not be manifolded together.


Clarifies the requirement since vent lines do not rupture, diaphragms can.






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To: Secretary, Standards Council National Fire Protection Association 1 Batterymarch Park ∙ Quincy, MA 02169-7471 OR



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Public Comment No. 28-NFPA 86-2013 [ Section No. 6.2.6.8.1 ]

6.2.6.8.1

Vents from systems operating at operating from different pressure levels pressure regulators shall not be manifoldedtogether.


The language 'at different pressure levels' can not be consistently enforced without knowing if 0.1"wc, 1"wc or 10"wc is considered different. By changing the wording to 'different pressure regulators', then there is a clear distinction and the format mirrors the following 6.2.6.8.2, which states 'different pressure-reducing stations'. NOTE: if the committee decides that pressure-reducting stations implies pressure regulators, then 6.2.6.8.1 should be deleted.




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6.2.7.1

Overpressure protection shall be provided in either of the following cases:

(1) When the supply pressure exceeds the pressure rating of any downstream component

(2) When the failure of a single upstream line regulator or service pressure regulator results in a supply pressure exceedingthe pressure rating of any downstream component



First_Revision_No_116_OPD.pdf Cover Sheet


Editorial.




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6.2.7 Overpressure Protection. 6.2.7.1 Overpressure protection shall be provided in either of the following cases: (1) When the supply pressure exceeds the pressure rating of any downstream component (2) When the failure of a single upstream line regulator or service pressure regulator results in a supply pressure exceeding the pressure rating of any downstream component


editorial








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6.2.7.4

Token relief valves and internal token relief valves shall not be permitted to be used as an OPD to comply with 6 .2.7.



First_Revision_No._116-OPD.pdf Cover Sheet


Clarified that use of token relieve valves are permitted, but no in order to comply with 6.2.7.




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6.2.7 Overpressure Protection. 6.2.7.1 Overpressure protection shall be provided in either of the following cases: (1) When the supply pressure exceeds the pressure rating of any downstream component (2) When the failure of single upstream line regulator or service pressure regulator results in a supply pressure exceeding the pressure rating of any downstream component 6.2.7.2 Overpressure protection shall be provided by any one of the following: (1) A series regulator in combination with a line regulator or service pressure regulator (2) A monitoring regulator installed in combination with a line regulator or service pressure regulator (3) A full-capacity pressure relief valve (4) An overpressure cutoff device, such as a slam-shut valve or a high-pressure switch in combination with an adequately rated shutoff valve 6.2.7.3* When a relief valve is used to comply with 8.2.10, the relief valve shall be a full-capacity relief type. 6.2.7.4 Token relief valves and internal token relief valves shall not be permitted to be used as an OPD to comply with 6.2.7.


Clarified that use of token relieve valves are permitted, but not in order to comply with 6.2.7.




I hereby grant and assign to the NFPA all and full rights in copyright in this Public Comment (including both the Proposed Text and the Statement of Problem and Substantiation). I understand that I acquire no rights in any publication of NFPA in which this Public Comment in this or another similar or


analogous form is used. Except to the extent that I do not have authority to make an assignment in materials that I have identified in (b) above, I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this assignment.




4/23/2013


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6.2.7.4

Token relief valves and internal token relief valves shall not be permitted to be used as an OPD as theonly overpressure prevention device .


The initials OPD should be expanded to words since the initials may not be immediately clear to a user. Add the word 'only' so that a device with token relief can be combined when used with other approved OPDs, such as a monitoring regulator system.




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7.4.10.1

Safety shutoff valves used to comply with 8.5.1.8(4) that and are not proved closed shall be replaced before they exceed theirmaximum allowable number of lifetime open–closed cycles.



First_Revision_No_30_purge_and_cycles.pdf Cover Sheet


Clarifies that two conditions exist when cycle counting is needed. 1) when skipping purge and 2) valves are not proved closed.




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(b) Section/Paragraph First Revision No. 30 pa




7.4.10.1 Safety shutoff valves used to comply with 8.5.1.8(4) that and are not proved closed shall be replaced before they exceed their maximum allowable number of lifetime open–closed cycles.


Clarifies that two conditions exist when cycle counting is needed . 1) when skipping purge and 2) valves are not proved closed.









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7.4.19*

Whenever combustible fuel gas piping is placed into service or removed from service, any release of combustible gas fuel gas

greater than a rate of 2.5 ft 3 /hr shall be vented to an approved location.



First_Revision_No_97.pdf Cover Sheet


Gas piping is not combustible. Need to define some minimum volume or release rate since the current language would require any release of gas during valve seat leakage testing to be vented to the outside. The release of bubbles during leak testing would pose a problem with this requirement as worded.




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7.4.19* Whenever combustible fuel gas piping is placed into service or removed from service, any release of combustible fuel gas greater than a rate of 2.5 ft3/hr shall be vented to an approved location.


Gas piping is not combustible. Need to define some minimum volume or release rate since the current language would require any release of gas during valve seat leakage testing to be vented to the outside. The release of bubbles during leak testing would pose a problem with this requirement as worded.









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8.2.11 *

Where transmitters are used in place of switches for safety functions, the following shall apply:

(1) The transmitter shall be safety integrity level (SIL) 2 capable.

(2) Transmitter failure shall be detected and initiate a safety shutdown.

(3) The transmitter shall be dedicated to safety service unless listed for simultaneous process and safety service.


The added condition was originally present in 8.4.4(2) before it was moved to 8.2.11 by First Revision No. 9-NFPA 86-2012. Re-inserting the missing text will keep 86 aligned with 87 and avoid confusion.




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8.3.1.3

Safety interlocks shall meet one or more of the following criteria:

(1) Be hardwired without relays in series and ahead of the controlled device

(2) Be connected to an input of a programmable controller logic system complying with Section 8.4

(3) Be connected to a relay that represents a single safety interlock which is configured to initiate safety shutdown in theevent of power loss

(4) Be connected to a listed safety relay that represents one or more safety interlocks and initiates safety shutdown uponpower loss





Clarified what initiates the lockout. The safety interlock, not the relay, initiates the shutdown.




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(b) Section/Paragraph First Revision No. 80 para 8.3.1.3




8.3.1.3 Safety interlocks shall meet one or more of the following criteria: (1) Be hardwired without relays in series and ahead of the controlled device (2) Be connected to an input of a programmable controller logic system complying with Section 8.4 (3) Be connected to a relay that represents a single safety interlock which is configured to initiate safety shutdown in the event of power loss (4) Be connected to a listed safety relay that represents one or more safety interlocks and initiates safety shutdown upon power loss


Clarified what initiates the lockout. The safety interlock, not the relay, initiates the shutdown.









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Public Comment No. 35-NFPA 86-2013 [ Section No. 8.4.2 [Excluding any Sub-Sections] ]

For PLCs , not that are not listed for combustion safety service, and safeguards,the

PLC and its associated I/O used to perform safety functions

shallshould be certified to IEC 61508 for use in

safety applications with a safety integrity level of 2 or greater

..and should be applied per the

manufacturer’s safety manual to meet a SIL-2 capable controller.


Add clarity to 1st edition requirements.


Submitter Full Name:Ted Jablkowski

Organization: Fives North American Combustion

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Submittal Date: Wed May 01 10:11:42 EDT 2013


I, Ted Jablkow ski, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment




By checking this box I aff irm that I am Ted Jablkow ski, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions



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Public Comment No. 36-NFPA 86-2013 [ New Section after 8.4.4 ]

TITLE OF NEW CONTENT

Type your content here ...

Add Annex:

8.4.4* Safety-related software should meet all of the following: (1) The BMS logic, memory, and I/O should be independent from non-safety logic and memory (2) The BMS logic, memory, and I/O should be protected from alteration by non-BMS logic or memory access(3) The BMS logic, memory, and I/O should be protected from alteration by unauthorized users


Add Annex material to explain software separation objectives based on a SIL 2 capable processor being capable of the secure separation of the BMS safety logic from the process logic versus a SIL 3 capability implying the need for redundancy which has not been discussed in the new requirements.




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8.4.4 Safety PLCs.

(A)

Where used for combustion safety service, safety programmable logic controllers shall have the following characteristics:

(1) The processor and the input and output (I/O) shall be listed for control reliable service with an SIL rating of at least 2.

(2) Access to PLCs dedicated to safety functions shall be restricted to the OEM or the designer/manufacturer .

(3) Nonsafety functions, where implemented, shall be independently accessible from safety functions.

(4)

(B)

Safety PLCs shall not implement the following:

(1) Manual emergency switches

(2) Continuous vapor concentration high-limit controllers



First_Revision_No_83_rev_1.pdf Cover Sheet


Defines the degree of restriction needed.




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* All safety function sensors and final elements shall be independent of operating sensors and final elements.





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8.4.4 Safety PLCs. (A) Where used for combustion safety service, safety programmable logic controllers shall have the following characteristics: (1) The processor and the input and output (I/O) shall be listed for control reliable service with an SIL rating of at least 2. (2) Access to PLCs dedicated to safety functions shall be restricted to the OEM or the designer/manufacturer. (3) Nonsafety functions, where implemented, shall be independently accessible from safety functions. (4) * All safety function sensors and final elements shall be independent of operating sensors and final elements.


Defines the degree of restriction needed.








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(1)

8.4.5

PLCs shall not implement the following:

(1) Manual emergency switches

(2) Continuous vapor concentration high-limit controllers


Delete 8.4.5 as the 1st edition does not acknowledge the use of general purpose PLC's except for pre-purge timing.




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Public Comment No. 37-NFPA 86-2013 [ Section No. 8.5.1.2(A) ]

(A)

At least 4 scf volumes of fresh air or inert gas per cubic foot (4 m 3 /m 3 ) of system volume shall gas shall be introducedduring the purging cycle.


The present requirement includes a contradiction in that in the requirement for 4 scf (standard cubic foot) is not on the same basis as (4 m3/m3). The purge requirement should be based on actual volume, not corrected for Standard or Normal conditions.




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8.5.1.8*

Repeating the pre-ignition purge shall not be required where any one of the following conditions is satisfied:

(1) The heating chamber temperature is proved above 1400°F (760°C).

(2) For a multiburner fuel-fired system not proved above 1400°F (760°C), all of the following conditions are satisfied:

(a)

(b) The burner(s) remaining in operation shall provide ignition of any unintended release of fuel through other burners thatare not in operation without explosion.

(3)

(4) All of the following conditions are satisfied (does not apply to fuel oil systems):

(a) The number of safety shutoff valves required to close in 8.8.1.3 and 8.8.2.1 will close between the burner system andthe fuel gas supply when that burner system is off.

(b) Safety shutoff valve seat leak testing is performed on at least a semiannual basis.

(c) The burner system uses natural gas, butane, or propane fuel gas.

(d)

(e) The minimum airflow used in the LFL calculation in 8.5.1.8(4)(d) is proved and maintained during the period theburner(s) are off.



First_Revision_No._29_.pdf Cover Sheet


The critical rate is the leakage into the combustion chamber, not the leakage of an individual valve in the case when two valves in series are installed at the burner. One can imagine two valves in series, 1 leaks and the other does not. The actual leakage to the burner is then 0.




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* At least one burner remains operating in the common combustion chamber of the burner to be re-ignited.

* For fuel gas–fired burner systems and assuming that all safety shutoff valves fail in the full open position, it can bedemonstrated that the combustible concentration in the heating chamber and all other passages that handle therecirculation and exhaust of products of combustion cannot exceed 25 percent of the LFL.

* It can be demonstrated based on the safety shutoff valve leakage rates leakage rate into the combustion chamber ,that the combustible concentration in the heating chamber and all other passages that handle the recirculation andexhaust of products of combustion cannot exceed 25 percent of the LFL.





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8.5.1.8* d) It can be demonstrated based on the safety shutoff valve leakage rates into the combustion chamber, that the combustible concentration in the heating chamber and all other passages that handle the recirculation and exhaust of products of combustion cannot exceed 25 percent of the LFL.


The critical rate is the leakage into the combustion chamber, not the leakage of an individual valve in the case when two valves in series are installed at the burner. One can imagine two valves in series, 1 leaks and the other does not. The actual leakage to the burner is then 0.









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8.5.2.1

The trial-for-ignition period of any pilot or main gas burner shall not exceed 15 seconds, unless both of the following conditionsare satisfied:

(1) A written request for an extension of the trial-for-ignition period is approved by the authority having jurisdiction.

(2) It is determined that 25 percent of the LFL cannot be exceeded in the extended time.


Editorial...add "of" before "any".




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8.5.2.1

The trial-for-ignition period of any pilot or main gas burner shall not exceed 15 seconds, unless both of the following conditionsare satisfied:

(1) A written request for an extension of the trial-for-ignition period is approved by the authority having jurisdiction.

(2) It is determined that 25 percent of the LFL cannot be exceeded in the extended time.



First_Revision_No_33_Recovered_.pdf Cover Sheet


Editorial.




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8.5.2.1 The trial-for-ignition period of any pilot or main gas burner shall not exceed 15 seconds, unless both of the following conditions are satisfied: of the pilot burner shall not exceed 15 seconds. (1) A written request for an extension of the trial-for-ignition period is approved by the authority having jurisdiction. (2) It is determined that 25 percent of the LFL cannot be exceeded in the extended time.


editorial









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Public Comment No. 39-NFPA 86-2013 [ Section No. 8.6.1 [Excluding any Sub-Sections] ]

Where a fan is essential for purge or safety ventilation of an oven or allied equipment, fan operation shall be proved andinterlocked into the safety circuitry Burner Management System .


Missed substituting "Burner Management System" for "safety circuitry".




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8.6.3

In any combustion system where the combustion air supply can be diverted to an alternate flow path than a burner (e.g., to aregenerative burner system’s exhaust path), that burner’s associated combustion air flow path valve(s) shall be proven open, andits alternate air flow path valve(s) shall be proven closed, before that burner’s fuel safety shutoff valve(s) are energized.


This requirement (also repeated as 8.7.6) is covered by 8.7.2 and should be deleted from the main body. It provides helpful information that can be included as Annex material for 8.7.2.




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8.6.3

In any combustion system where the combustion air supply can be diverted to an alternate flow path other than to a burner(e.g., to a regenerative burner system’s exhaust path), that burner’s associated combustion air flow path valve(s) shall be provenopen, and its alternate air flow path valve(s) shall be proven closed, before that burner’s fuel safety shutoff valve(s) are energized.





Editorial.




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8.6.3 In any combustion system where the combustion air supply can be diverted to an alternate flow path other than to a burner (e.g., to a regenerative burner system’s exhaust path), that burner’s associated combustion air flow path valve(s) shall be proven open, and its alternate air flow path valve(s) shall be proven closed, before that burner’s fuel safety shutoff valve(s) are energized.


Editorial









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8.6.3



8.6.3 and 8.7.6 are identical. Delete 8.6.3 and leave 8.7.6 requirement under Combustion Air.




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8.7.6



Duplicate of 8.6.3, but also this requirement is covered generally by8.7.2. The information should be moved as Annex material for 8.7.2.




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Public Comment No. 45-NFPA 86-2013 [ New Section after 8.8.3.2 ]

8.8.3.3

Where an oil safety shutoff valve is required to be proved closed in 8.8.3.2, it shall be accomplished by the use of a proof-of-closure switch incorporated in a listed safety shutoff valve assembly in accordance with the terms of the listing.


The current wording for oil valve POC switches is inconsistent with that of fuel gas POC switches (section 8.8.2.2). Adding the requirement that the POC switch shall be incorporated in "listed safety shutoff valve" ensures oil shutoff valves are held to the same standard as fuel gas shutoff valves.


Submitter Full Name:Aaron Zoeller

Organization: SCC, Inc.

Street Address:

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Submittal Date: Thu May 02 16:49:05 EDT 2013


I, Aaron Zoeller, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment




By checking this box I aff irm that I am Aaron Zoeller, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions



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8.9.1

A low fuel pressure switch pressure sensor shall be provided and shall be interlocked into the burner management system.


Consider substituing "sensor" for "switch" here and, if acceptable, change everywhere in the Standard.




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8.9.2

A high fuel pressure switch pressure sensor shall be provided and shall meet the following criteria:

(1) It shall be interlocked into the burner management system.

(2) It shall be located downstream of the final pressure-reducing regulator.






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8.9.3

Pressure switch Pressure sensor settings shall be made in accordance with the operating limits of the burner system.






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Public Comment No. 33-NFPA 86-2013 [ Section No. A.8.5.1.8(4)(d) ]

A.8.5.1.8(4)(d)

In accordance with 8.5.1.8 (4)(c), fuels other than natural gas, butane, or propane may require additional consideration. Theseadditional considerations would be addressed using Section 1.5 . The concern with other fuel gases is the variability of fuel gascontent being delivered over time. Specific examples include landfill gas and bio gas.

The following sample calculation illustrating the use of 8.5.1.8 (4)(d) is provided to demonstrate a method of determining the25% LFL requirement.

The sample calculation is based upon the following assumptions:

(1) The fuel is methane gas.

(2) All burners are turned off for control purposes. All safety shutoff valves are de-energized.

(3) At each burner, two safety shutoff valves are closed, or a single shutoff valve is proven closed.

(4) All safety shutoff valves are tested for seat leakage at least semiannually.

(5) Safety shutoff valve seat leakage is assumed to be 1 scfh (0.0283 m 3 /hr @ 21°C).

The following thoughts are offered regarding the selection of the 1 scfh (0.0283 m 3 /hr @ 21°C) safety shutoff valve seatleakage rate.

Limited data reviewed by the committee indicates that valve seat leakage rates over 1 scfh (0.0283 m 3 /hr @ 21°C) are notanticipated unless the safety shutoff valve seats are exposed to extremely unusual conditions such as corrosives in the fuel gasor furnace heat allowed to back up the fuel line and burn the safety shutoff valve seat. The former condition is the basis forlimiting the use of 8.5.1.8 (4) to furnaces using natural gas, butane, or propane fuel gases. The latter condition occurred in acase where a fuel line was inappropriately opened by maintenance staff while the furnace was in operation. The furnace waspromptly shut down, and the safety shutoff valves were replaced.

Under operating conditions expected by this standard, it is anticipated that debris from internal fuel gas line oxidation (rust),pipe thread shavings not removed before fuel line assembly, or similar exposures can subject one safety shutoff valve to seatdamage that can lead to seat leakage of one safety shutoff valve; however, it is not expected that both safety shutoff valves

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would experience similar seat leakage. The selected safety shutoff valve seat leakage rate of 1 scfh (0.0283 m 3 /hr @ 21°C)isconsidered conservative.

Overall, this sample calculation is based upon the following conservative conditions:

(1) The use of a 1 scfh (0.0283 m 3 /hr @ 21°C) safety shutoff valve seat leakage rate.

(2) Providing two safety shutoff valves for each fuel path

(3) Using valve proving to prove each safety shutoff valve closed Closing two valves or using proof of closure if closing one valve

(4) Assuming safety shutoff valve leakage at each burner fuel path

(5) Using a design limit of 25 percent of LFL

(6) Including the effects of elevated furnace temperature on the LFL

(7) Assuming no fuel exits the furnace

The effects of temperature on fuel gas LFL were obtained from a United States Department of the Interior, Bureau of MinesBulletin 680, “Investigation of Fire and Explosion Accidents in the Chemical, Mining, and Fuel-Related Industries — A Manual.”Figure 34 in that bulletin, “Temperature effect on lower limits of flammability of 10 normal paraffins in air at atmosphericpressure,” shows temperature (°C) versus combustibles (volume percent) and includes curves for methane, butane, andpropane. It also includes a formula for computing LFL at elevated temperature. That formula, based on Bureau of Mines Bulletin627, “Flammability Characteristics of Combustible Gases and Vapors,” is as follows:

where:

L T = LFL at the desired elevated temperature, T (°C)

L 25 = LFL at 25°C

T = Desired elevated temperature (°C)

Sample Problem — U. S. Customary Units

Objective. Calculate the amount of time that all burners can be turned off before the furnace atmosphere will reach 25% ofLFL.

Assumptions. Furnace contains no combustibles when the burners are turned off. Furnace is under positive pressure with noair infiltration.

Given the following information:

Furnace type: Batch

Furnace size: 8 ft wide × 6 ft deep × 8 ft tall

Number of burners: 5

Burner design rate: 0.8 MM Btu/hr

Burner design excess air: 10.0%

Burner design air capacity: 8800 scfh

Burner air minimum design flow: 100 scfh

Maximum leak rate each flow path*: 1 scfh

Number of burner flow paths**: 5

Furnace temperature: 900°F or 482°C

Oxygen in furnace atmosphere: 18%

Fuel: Methane

*The flow path is across one set of closed safety shutoff valves proven closed .

**The number of flow paths is the number of sets of safety shutoff valves which are closed that can leak into the furnaceenclosure.

Step 1. Determine LFL at 900°F using the formula from above:

Step 2. Determine the furnace volume:

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Step 3. Determine the methane leak rate into the furnace with all burners off:

Step 4. Determine the airflow into the furnace with all burners off:

Step 5. Determine the percent volume methane to air through all burners:

Step 6. Determine the percent LFL resulting from the methane flow through all burner fuel paths at 900°F:

Step 7. Determine the time in minutes to reach 25% LFL with all burners off:

Conclusions. Where the value of % LFL 900°F exceeds 25 percent, the burner safety shutoff valves can remain closed and

burners be reignited without a repurge within a period of time not exceeding t FCE 25% LFL . After t FCE 25% LFL is

exceeded, a repurge of the furnace is required.

Where the value of % LFL 900°F equals or is less than 25 percent, burners can be reignited at any time as long as the airflow

rate Q AIR is proven and interlocked in the burner management system such that loss of this proven airflow rate will require a

repurge of the furnace before burner reignition is permitted.

Sample Problem — SI Units

Objective. Calculate the amount of time that all burners can be turned off before the furnace atmosphere will reach 25% ofLFL.

Assumptions. Furnace contains no combustibles when the burners are turned off. Furnace is under positive pressure with noair infiltration.

Given the following information:

Furnace type: Batch

Furnace size: 2.438 m wide × 1.828 m deep × 2.428 m tall

Number of burners: 5

Burner design rate: 234.2 kW

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Burner design excess air: 10.0%

Burner design air capacity: 249.2 m 3 /hr @ 21°C

Burner air minimum design flow: 2.83 m 3 /hr @ 21°C

Maximum leak rate each flow path*: 0.0283 m 3 /hr @ 21°C

Number of burner flow paths**: 5

Furnace temperature: 900°F or 482°C

Oxygen in furnace atmosphere: 18%

Fuel: Methane

*The flow path is across one set of closed safety shutoff valves proven closed .

**The number of flow paths is the number of sets of safety shutoff valves which are closed that may leak into the furnaceenclosure.

Step 1. Determine LFL at 482°C using the formula from above:

Step 2. Determine the furnace volume:

Step 3. Determine the methane leak rate into the furnace with all burners off:

Step 4. Determine the airflow into the furnace with all burners off:

Step 5. Determine the percent volume methane to air through all burners:

Step 6. Determine the percent LFL resulting from the methane flow through all burner fuel paths at 482°C:

Step 7. Determine the time in minutes to reach 25 percent LFL with all burners off:

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Conclusions. Where the value of % LFL 482°C exceeds 25 percent, the burner safety shutoff valves can remain closed and

burners be reignited without a repurge within a period of time not exceeding t FCE 25% LFL . After t FCE 25% LFL is

exceeded, a repurge of the furnace is required.

Where the value of % LFL 482°C equals or is less than 25 percent, burners can be reignited at any time as long as the

airflow rate Q AIR is proven and interlocked in the burner management system such that loss of this proven airflow rate will

require a repurge of the furnace before burner reignition is permitted.


Main body text of 8.5.1.8.4 does not require valve proof of closure unless closing only 1 valve under 8.8.1.3.




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Public Comment No. 13-NFPA 86-2013 [ Section No. A.8.9 ]

A.8.9

A system designer can choose to use pressure switches in a pilot. However, gas pressure switches on a pilot can be desirable,and the following conditions should be considered in deciding whether or not switches should be used:

(1) If it’s a continuous pilot. If a reliable pilot after light off is still a desirable part of the safety during operation of the burner,the switches help prove the reliability of the pilot so that the gas pressure to the pilot is proven to be within designedparameters.

(2) If the pilot burner capacity is above 400,000 Btu/hr. Direct sparking a burner in excess of 400,000 Btu/hr could introduceadded risks if a delayed ignition occurs due to too much or too little gas pressure.

(3) If the pilot burner uses its own pressure regulator. Failure of that regulator could cause instability of the burner or exposedownstream components to pressures exceeding their ratings.

(4) If the inlet pressure to the pilot regulator exceeds ½ psi. The higher the pressure to the pilot burner, the greater the risk ofa problem due to incorrect gas pressure. The failure or overloading of a pilot regulator can be at a significantly higher riskwhere inlet pressures to the pilot regulator exceed ½ PSI.

(5) Where providing overpressure protection for a pilot line in order to comply with 8.2.10, a high gas pressure switch on thepilot line in combination with a shutoff valve may be used.



First_Revision_No._108_.pdf Cover Sheet


Make it a indent #5. Editorial.




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Public Comment No. 16-NFPA 86-2013 [ Section No. A.8.10.1.3 ]





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(b) Section/Paragraph First Revision No. 108 para A.8.9




A.8.9 A system designer can choose to use pressure switches in a pilot. However, gas pressure switches on a pilot can be desirable, and the following conditions should be considered in deciding whether or not switches should be used: (1) If it’s a continuous pilot . If a reliable pilot after light off is still a desirable part of the safety during operation of the burner, the switches help prove the reliability of the pilot so that the gas pressure to the pilot is proven to be within designed parameters. (2) If the pilot burner capacity is above 400,000 Btu/hr . Direct sparking a burner in excess of 400,000 Btu/hr could introduce added risks if a delayed ignition occurs due to too much or too little gas pressure. (3) If the pilot burner uses its own pressure regulator . Failure of that regulator could cause instability of the burner or expose downstream components to pressures exceeding their ratings. (4) If the inlet pressure to the pilot regulator exceeds ½ psi . The higher the pressure to the pilot burner, the greater the risk of a problem due to incorrect gas pressure. The failure or overloading of a pilot regulator can be at a significantly higher risk where inlet pressures to the pilot regulator exceed ½ PSI. (5) Where providing overpressure protection for a pilot line in order to comply with 8.2.10, a high gas pressure switch on the pilot line in combination with a shutoff valve may be used.


Make it a indent #5. Editorial




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A.8.10.1.3

Subsections 8.2.1, 8.2.2, and 8.2.5 require the combustion safeguard be listed, applied, and installed according to themanufacturer’s instructions. Manufacturer’s instructions can limit the operating time of a combustion safeguard withoutshutdown and safe-start check or a self-checking logic. Figure A.8.10.1.3 shows the difference between flame response time(FRT) and flame failure response time (FFRT).

Figure A.8.10.1.3 Example of the Difference Between FRT and FFRT.

Change the diagram to delete "Flame" with "Actual Loss of Flame"; delete "No Flame" with "Detected Loss of Flame" and Add"Power Loss to the" before "SSOV".



First_Revision_No._108.pdf Cover Sheet


Diagram is ambiguous.Is FLAME the real loss of flame or the point in time when the flame detected sees the loss of flame?Same with NO FLAME. Is this the real loss of flame or the point in time when the flame detected sees the loss of flame? Idea is that one must use a flame detector that detects within 4 secs the actual loss of flame. One cannot use a detect that is not have a quick enough response.Time SSOV should clarify that at time = 4 sec. the terminals of the SSOV should loss power.




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FOR OFFICE USE ONLY

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(b) Section/Paragraph First Revision No. 108 para A.8.10.1.3




A.8.10.1.3.

Revise the diagram as follows Flame Actual Loss of Flame No Flame Detected Loss of Flame Power Loss to the SSOV


Diagram is ambiguous.

Is FLAME the real loss of flame or the point in time when the flame detected sees the loss of flame?

Same with NO FLAME. Is this the real loss of flame or the point in time when the flame detected sees the loss of flame? Idea is that one must use a flame detector that detects within 4 secs the actual loss of flame. One cannot use a detect that is not have a quick enough response.

Time SSOV should clarify that at time = 4 sec. the terminals of the SSOV should loss power.









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Public Comment No. 27-NFPA 86-2013 [ Section No. A.8.10.1.3 ]

A.8.10.1.3

Subsections 8.2.1, 8.2.2, and 8.2.5 require the combustion safeguard be listed, applied, and installed according tothe manufacturer’s instructions. Manufacturer’s instructions can limit the operating time of a combustion safeguardwithout shutdown and safe-start check or a self-checking logic. Figure A.8.10.1.3 shows the difference betweenflame detector response time ( FRT FDRT ) and flame failure response time (FFRT).

Figure A.8.10.1.3 Example of the Difference Between FRT FDRT and FFRT.



FigA-10-8-1-3.jpg Figure A.10.8.1.3


If the definitions FDRT and FFRT are changed to avoid confusion with industry standards, CSA C22.2 NO. 199 / ANSI Z21.20 / UL 372 then this section also needs to be changed accordingly. See PC No. 25-26.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 25-NFPA 86-2013 [Section No. 3.3.18] Definition changed to FDRT

Public Comment No. 26-NFPA 86-2013 [Section No. 3.3.20] Definition changed to FFRT




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Public Comment No. 3-NFPA 86-2013 [ Section No. F.3 ]

F.3 Steam Outlets.

If steam is used, steam outlets should be sufficiently large to supply 8 lb/min (3.6 kg/min) of steam for each 100 ft3 (2.8 m3) ofoven volume. The outlets preferably should be located near the bottom of the oven, but if the oven is not over 20 ft (6.1 m) high,they might be located near the top, pointing downward. Steam jets should be directed at dip tanks (in a manner to avoiddisturbing the liquid surface) or other areas of special hazard.

My comment: Could you please provide (justify) the calculation basis for such high flow rate of snuffing/ smothering steam perone hundred cubic feet?


The quantity required for snuffing or smothering steam seems to be high whicvh require additional cost to provide large quantity of steam.


Submitter Full Name:Srini Jeyakumar

Organization: Suncor Energy Inc

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Submittal Date: Tue Apr 02 14:06:47 EDT 2013


I, Srini Jeyakumar, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment




By checking this box I aff irm that I am Srini Jeyakumar, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions

